`Patent 8,061,598 B2
`UNITED STATES PATENT AND TRADEMARK OFFICE
`______________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________________
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`APPLE INC.,
`Petitioner
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`v.
`
`SMARTFLASH LLC,
`Patent Owner
`______________________
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`Case CBM2015-00120
`Patent 8,061,598 B2
`______________________
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`Before the Honorable JENNIFER S. BISK, RAMA G. ELLURU, GREGG I.
`ANDERSON, and PETER P. CHEN, Administrative Patent Judges.
`
`
`NOTICE THAT PETITIONER APPLE INC.’S
`MOTION FOR JOINDER (PAPER 3) IS UNOPPOSED
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`
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`On June 29, 2015, the Board authorized the undersigned, on behalf of and
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`acting in a representative capacity for Petitioner Apple Inc. (“Petitioner”), to
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`submit a notice stating that Apple’s Motion for Joinder (Paper 3) is not opposed by
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`Patent Owner Smartflash LLC (“Patent Owner”).
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`
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`On April 30, 2015 and concurrently with its Petition, Petitioner filed a
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`Motion for Joinder requesting joinder of its Petition with pending Covered
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`Business Method review CBM2014-00193, which was instituted by the Board on
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`April 2, 2015. Paper 3 at 2. At the May 4, 2015 telephonic conference with the
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`Case CBM2015-00120
`Patent 8,061,598 B2
`Board, Patent Owner’s counsel stated that Patent Owner “will oppose the motion
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`under 325(c).” See Paper 10 at 16:11-20. The Board’s May 6, 2015 Order on the
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`Conduct of Proceedings set a June 1, 2015 due date for Patent Owner’s opposition
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`to Petitioner’s Motion for Joinder. Paper 6 at 3. However, on June 1, 2015, Patent
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`Owner only filed a preliminary response, stating therein that “[i]f the Board
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`institutes a CBM review, Patent Owner does not oppose Petitioner’s Motion for
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`Joinder, Paper 3.” Paper 9 at 1 n.1. Accordingly, Petitioner’s pending Motion for
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`Joinder (Paper 3) is unopposed, and Petitioner is prepared to provide any further
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`information in connection with the request for joinder as the Board may require.
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`Respectfully submitted,
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`
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`July 1, 2015
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`
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`Ching-Lee Fukuda (Backup Counsel)
`Reg. No. 44,334
`ROPES & GRAY LLP
`1211 Avenue of the Americas
`New York, NY 10036
`P: 212-596-9336 /F: 212-596-9000
`ching-lee.fukuda@ropesgray.com
`
`By:/J. Steven Baughman/
`J. Steven Baughman (Lead Counsel)
`Reg. No. 47,414
`Megan Raymond (Backup Counsel)
`Reg. No. 72,997
`ROPES & GRAY LLP
`One Metro Center, 700 12th St.
`Suite 900
`Washington, DC 20005-3948
`P: 202-508-4606 / F: 202-383-8371
`steven.baughman@ropesgray.com
`Mailing address for all PTAB correspondence: ROPES & GRAY LLP
`IPRM – Floor 43, Prudential Tower, 800 Boylston Street, Boston, MA 02199-
`3600
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`Attorneys for Petitioner Apple Inc.
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`Case CBM2015-00120
`Patent 8,061,598 B2
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that a copy of the foregoing NOTICE
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`THAT PETITIONER APPLE INC.’S MOTION FOR JOINDER (PAPER 3) IS
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`UNOPPOSED was served on July 1, 2015, to the following Counsel for Patent
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`Owner via e-mail, pursuant to the parties’ agreement concerning service:
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`Michael R. Casey
`J. Scott Davidson
`DAVIDSON BERQUIST JACKSON & GOWDEY LLP
`8300 Greensboro Drive, Suite 500
`McLean, VA 22102
`Telephone: (571) 765-7700
`Facsimile: (571) 765-7200
`mcasey@dbjg.com
`jsd@dbjg.com
`docket@dbjg.com
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`Attorneys for Patent Owner Smartflash LLC
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`/s/ Sharon Lee
`Sharon Lee
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`
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`ROPES & GRAY LLP
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